In early May, the U.S. Occupational Safety and Health Administration (OSHA) published a new standard for confined spaces
in construction under 29 CFR 1926 Part AA .This extensive document includes definitions and regulations for all confined space situations that went into effect on August 3, 2015. Shortly after this publication, OSHA published a two-page guidance document "OSHA 3787 Confined Spaces in Construction: Crawlspaces and Attics
." This guidance document specifically identifies the application of SPF and highlights potential confined space hazards associated with attics and crawlspaces.
Enforcement of the Confined Spaces in Construction standard published on May 4, 2015 for residential construction work has changed. The new standard went into effect on August 3, 2015. A temporary enforcement policy has been in effect for all employers covered by the standard through October 2, 2015. OSHA now further extends this temporary enforcement policy through January 8, 2016, only for employers engaged in residential construction work. Before January 8, 2016, OSHA will not issue citations under the Confined Spaces in Construction standard to an employer engaged in residential construction work if the employer is making good faith efforts to comply with the standard, as long as the employer is in compliance with either the training requirements of the standard, found at 29 CFR 1926.1207
, or the former training requirements found at 29 CFR 1926.21(b)(6)(i)
Under the OSHA definition, many existing attics and all crawlspaces will qualify as a confined space: "any space large enough for workers to enter and perform certain jobs...with a limited or restricted means for entry/exit and not designed for continuous occupancy." The new standard provides employers with information on protecting employees working in confined spaces and establishes specific requirements for working in permit-required confined spaces. Permit-space regulations may require additional labor (e.g., attendants, rescue and retrieval personnel), worker training and administrative activities (e.g., site evaluation, permit systems, signage and other documentation).
The presence of a hazardous atmosphere is the primary factor for determining if a confined space is a permit-required space. According to the OSHA standard, a hazardous atmosphere can occur when:
1. Concentrations of airborne chemicals exceed 10% of the lower flammability limit (LFL).
2. Airborne flammable particles can be ignited, which may exist from SPF cutting and trimming operations.
3. Oxygen levels are deficient (below 19.5%) or enriched (above 23.5%).
4. Any airborne chemical exceeds occupational exposure limits (OELs).
5. Conditions are immediately dangerous to life or health (IDLH) that can interfere with an employee’s ability to self-rescue.
The new OSHA standard is being reviewed by the industry to determine any potential impacts on the use of spray foam products in attics and crawlspaces. In every space and job type, SPF contractors are always encouraged to follow industry best practices for proper ventilation strategies and proper use of personal protective equipment consistent with industry guidelines for these applications. Additional information on the new standard is available on the OSHA website